Brainscape's Knowledge GenomeTM

Browse over 1 million classes created by top students, professors, publishers, and experts.


See full index

Transfer Pricing > Transfer Pricing Terms > Flashcards

Transfer Pricing Terms Flashcards

1
Q

Transfer Pricing

A

The setting of prices for transactions between related entities within a multinational corporation.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
2
Q

Arm’s Length Principle

A

The standard that transfer prices should be the same as those charged between unrelated parties under similar circumstances.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
3
Q

Comparable Uncontrolled Price (CUP) Method

A

A transfer pricing method that compares the price charged in a controlled transaction to the price charged in a comparable uncontrolled transaction.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
4
Q

Cost Plus Method

A

A transfer pricing method that adds an appropriate markup to the costs incurred by the supplier in a controlled transaction.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
5
Q

Resale Price Method

A

A transfer pricing method that determines the transfer price based on the resale price to an independent party, minus an appropriate gross margin.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
6
Q

Transactional Net Margin Method (TNMM)

A

A transfer pricing method that examines the net profit margin relative to an appropriate base (e.g., costs, sales) that a taxpayer realizes from a controlled transaction.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
7
Q

Profit Split Method

A

A transfer pricing method that allocates the combined profits from controlled transactions based on the relative value of each party’s contribution.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
8
Q

Functional Analysis

A

An analysis of the functions performed, risks assumed, and assets used by each party in a controlled transaction.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
9
Q

Benchmarking

A

The process of comparing a company’s transfer prices to those of comparable uncontrolled transactions.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
10
Q

Transfer Pricing Documentation

A

Documentation that supports the arm’s length nature of a company’s transfer pricing policies and practices.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
11
Q

Advance Pricing Agreement (APA)

A

An agreement between a taxpayer and tax authority on the appropriate transfer pricing methodology for future transactions.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
12
Q

Base Erosion and Profit Shifting (BEPS)

A

Strategies used by multinational companies to shift profits from high-tax jurisdictions to low-tax jurisdictions, eroding the tax base of the high-tax jurisdictions.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
13
Q

Country-by-Country Reporting (CbCR)

A

A BEPS initiative requiring multinational enterprises to report income, taxes paid, and other indicators of economic activity for each country in which they operate.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
14
Q

Controlled Transaction

A

A transaction between two related entities within a multinational corporation.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
15
Q

Uncontrolled Transaction

A

A transaction between two unrelated entities.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
16
Q

Comparable

A

An uncontrolled transaction or entity that is similar to the controlled transaction or entity being analyzed.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
17
Q

Intangible Property

A

Non-physical assets such as patents, trademarks, and copyrights that can be transferred between related entities.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
18
Q

Tangible Property

A

Physical assets such as machinery, equipment, and inventory that can be transferred between related entities.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
19
Q

Royalty

A

A payment made for the use of intangible property.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
20
Q

Intercompany Agreement

A

A contract between related entities that outlines the terms and conditions of their transactions.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
21
Q

Transfer Pricing Adjustment

A

An adjustment made by tax authorities to a company’s transfer prices to ensure they reflect arm’s length prices.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
22
Q

Transfer Pricing Risk

A

The risk that a company’s transfer pricing practices will be challenged by tax authorities.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
23
Q

Transfer Pricing Policy

A

A company’s approach to setting transfer prices for transactions between related entities.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
24
Q

Transfer Pricing Audit

A

An examination of a company’s transfer pricing practices by tax authorities.

25
Q

Transfer Pricing Penalty

A

A fine imposed by tax authorities for non-compliance with transfer pricing regulations.

26
Q

Transfer Pricing Dispute

A

A disagreement between a taxpayer and tax authorities over the appropriate transfer prices for controlled transactions.

27
Q

Transfer Pricing Litigation

A

Legal proceedings to resolve a transfer pricing dispute.

28
Q

Transfer Pricing Adjustment Mechanism

A

Procedures for making adjustments to transfer prices to ensure they reflect arm’s length prices.

29
Q

Transfer Pricing Compliance

A

The process of ensuring that a company’s transfer pricing practices comply with tax regulations.

30
Q

Transfer Pricing Strategy

A

A company’s plan for managing its transfer pricing practices to minimize tax risk and optimize tax outcomes.

31
Q

Transfer Pricing Policy Framework

A

The set of principles and guidelines that govern a company’s transfer pricing practices.

32
Q

Transfer Pricing Methodology

A

The approach used to determine the appropriate transfer prices for controlled transactions.

33
Q

Transfer Pricing Study

A

An analysis conducted to determine the arm’s length nature of a company’s transfer prices.

34
Q

Transfer Pricing Report

A

A document that summarizes the findings of a transfer pricing study.

35
Q

Transfer Pricing Adjustment Notice

A

A notification from tax authorities that a company’s transfer prices have been adjusted.

36
Q

Transfer Pricing Penalty Notice

A

A notification from tax authorities that a company has been fined for non-compliance with transfer pricing regulations.

37
Q

Transfer Pricing Dispute Resolution

A

The process of resolving a transfer pricing dispute between a taxpayer and tax authorities.

38
Q

Transfer Pricing Litigation Strategy

A

A company’s plan for managing transfer pricing litigation.

39
Q

Transfer Pricing Adjustment Appeal

A

A request for a review of a transfer pricing adjustment by tax authorities.

40
Q

Transfer Pricing Penalty Appeal

A

A request for a review of a transfer pricing penalty by tax authorities.

41
Q

Transfer Pricing Dispute Settlement

A

The resolution of a transfer pricing dispute through negotiation or arbitration.

42
Q

Transfer Pricing Litigation Settlement

A

The resolution of transfer pricing litigation through negotiation or arbitration.

43
Q

Transfer Pricing Adjustment Settlement

A

The resolution of a transfer pricing adjustment through negotiation or arbitration.

44
Q

Transfer Pricing Penalty Settlement

A

The resolution of a transfer pricing penalty through negotiation or arbitration.

45
Q

Transfer Pricing Dispute Management

A

The process of managing transfer pricing disputes to minimize tax risk and optimize tax outcomes.

46
Q

Transfer Pricing Litigation Management

A

The process of managing transfer pricing litigation to minimize tax risk and optimize tax outcomes.

47
Q

Transfer Pricing Adjustment Management

A

The process of managing transfer pricing adjustments to minimize tax risk and optimize tax outcomes.

48
Q

Transfer Pricing Penalty Management

A

The process of managing transfer pricing penalties to minimize tax risk and optimize tax outcomes.

49
Q

Transfer Pricing Dispute Resolution Mechanism

A

Procedures for resolving transfer pricing disputes between taxpayers and tax authorities.

50
Q

Transfer Pricing Litigation Resolution Mechanism

A

Procedures for resolving transfer pricing litigation between taxpayers and tax authorities.

51
Q

Transfer Pricing Adjustment Resolution Mechanism

A

Procedures for resolving transfer pricing adjustments between taxpayers and tax authorities.

52
Q

Transfer Pricing Penalty Resolution Mechanism

A

Procedures for resolving transfer pricing penalties between taxpayers and tax authorities.

53
Q

Transfer Pricing Dispute Resolution Framework

A

The set of principles and guidelines that govern the resolution of transfer pricing disputes.

54
Q

Transfer Pricing Litigation Resolution Framework

A

The set of principles and guidelines that govern the resolution of transfer pricing litigation.

55
Q

Transfer Pricing Adjustment Resolution Framework

A

The set of principles and guidelines that govern the resolution of transfer pricing adjustments.

56
Q

Transfer Pricing Penalty Resolution Framework

A

The set of principles and guidelines that govern the resolution of transfer pricing penalties.

57
Q

Transfer Pricing Dispute Resolution Strategy

A

A company’s plan for managing transfer pricing disputes to minimize tax risk and optimize tax outcomes.

58
Q

Transfer Pricing Litigation Resolution Strategy

A

Transfer Pricing (2 decks)

Brainscape helps you reach your goals faster, through stronger study habits.
© 2024 Bold Learning Solutions. Terms and Conditions